CODE OF CONDUCT (GEDRAGSCODE)

Introduction

In our business ‘respect’ is the key word to almost any challenge. Respect gives a positive feeling of esteem to a person or business. Respect is preventive rather than aggressive. As an assurance provider respecting the business of our clients is an imperative that should never be disregarded. The fundament underneath Corporate Social Responsibility (CSR) is respect for life, now and for future generations.

As FIRA Sustainability B.V. (further referred to as FIRA) we recognize the importance of social responsibility and we are dedicated to ensure the interests of our clients, employees, shareholders and society, through practical practices.
In fact, our sole purpose as a business is allocating shared value. By connecting sustainable initiatives of companies to those of their customers, suppliers and other stakeholders, a chain can be created in which a viable business case for sustainability is present in every link. This leads to collaboration, in which everyone involved can really make a difference while remaining profitable.

Our Commitment

As FIRA we subscribe to the principles of social responsibilities, as defined in ISO26000, and we ask our employees to do the same:

• Accountability: be accountable for our impacts on society, the economy and the environment;

• Transparency: be transparent in our decisions and activities that impact on society and environment;

• Ethical behaviour: engage in ethically behaviour at all times;

• Respect for stakeholder interest: respect, consider, and respond to the interest of its stakeholders;

• Respect for the rule of law: accept that respect for the rule of law is mandatory;

• Respect for international norms of behaviour: respect international norms of behaviour, while adhering to the principle of respect for the rule of law;

• Respect for human rights: respect human rights and recognize both their importance and their universality.

In this code of conduct practical conduct based on the above principles is described. All employees must ensure that their day-to-day decisions are taken in conformity with the requirements of the Code of Conduct.

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Code of Conduct

These values are the very "essence" of FIRA, to which each of us subscribes.

We respect all individuals

• We understand the impact that our individual behaviour has on our business, our colleagues, and society, and always work to take responsible action.

• We show others the consideration they deserve.

• We always consider how our actions will affect others.

• We respect differences, care about others and do not discriminate against others on the basis of nationality, ethnic origin, age, sex or religious or political beliefs. We are fair in our behaviour and our policies promote equal opportunity for all.

We act with honesty and integrity

• We are straightforward and honest in our professional and business relationships.

• We are truthful about the services we provide, the knowledge we possess, and experience we gained.

• We do not misuse information of our clients, our business, or our people for personal advantage or for the benefit of third parties.

We are objective in forming our professional opinions

• We do not allow bias, conflict of interest, or undue influence of others to override our professional judgments.

• We address differences of opinion and handle them constructively and professionally.

• We draft reports which are accurate records of actions in line with our best practices.

We bring appropriate skills and capabilities to our clients

• We understand our clients and stakeholders expect our work to meet high professional standards.

• We use due care to ensure that client needs are matched with personnel who have the competence required for their assignments.

We act as professionals

• We respond as quick as possible to client needs.

• We comply with and go beyond professional standards and applicable laws and regulations, including international norms of behaviour. We strive not only to do what is legal, but also what is right.

• We avoid any actions that may discredit our business or our professions.

• We do not disclose confidential information to anyone inside or outside our businesses without the legal or professional right to know.

We lead by example, using our shared values as our foundation

• We recognize that we are role models and that we set behavioral standards for our professions and each other.

• We make decisions based on shared values and expect our leaders and colleagues to do the same: Integrity; Outstanding value to markets and clients; and Commitment to each other.

We are committed to fair practices and recognize/respect the impact we have on the world around us

• We receive fees that reflect the value of services provided and responsibilities assumed, and are considered fair and reasonable by our clients.

• We respect our competitors and do not compete unfairly.

• We take our role in society seriously and do not cause intentional harm.

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Impartiality and independence

We avoid situations in which our independence or impartiality may be compromised. We are committed to examining and dealing with such situations openly and transparently. Our work shall be carried out honestly in a professional, independent and impartial manner, with no influence tolerated with respect to any deviation from either our own approved methods and procedures or the reporting of accurate results. We shall not bow to any pressure or influence. 
Data, test results and other material facts shall be reported in good faith. Our reports and statements shall accurately state the actual findings, professional opinion or results obtained.

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Record keeping

We safeguard the accuracy of all client related and internal business records of FIRA, including records such as verification reports, assurance statements, time records, financial and expense reports, and submissions such as benefit claim forms and resumes. 
We see ensuring accurate and complete business records as a shared responsibility in which we take our role as accurate record keeping and reporting reflects on FIRA’s reputation and credibility. As we audit clients we are auditable ourselves. We:

• Ensure that all proposals and reports to clients and regulatory authorities are full, fair, accurate, timely and understandable and supported by appropriate documentation, based on our best judgment.

• Strive to always record and classify transactions in the proper accounting period and in the appropriate account. We do not delay or accelerate reporting and the recording of revenue or expenses.

• Never falsify any document and do not distort the true nature of any transaction.

We safeguard the company’s nonpublic information at all times, including outside of the workplace and working hours, and even after employment ends. We do not disclose nonpublic information to others inside the company unless there is a business reason to know. We do not disclose confidential information to anyone outside FIRA, including family and friends. As we disclose information required by law or business need we take appropriate steps, such as execution of a confidentiality agreement, to prevent misuse of the information. 
We effectively use IT systems and do not keep client and or nonpublic information on our lap-top/computer/phone. We will record FIRA information on our secured network to not expose FIRA to serious legal risks.

Confidentiality and nonpublic information

Nonpublic information is any information that FIRA has not disclosed or made generally available to the public. Examples include, but are not limited to, information related to: employee or client information, contracts, strategic and business plans, financial data, client information or evidence labeled confidential and/or clients best practices, etc.

Conflicts of interest

A conflict of interest is a situation in which the Group's interests differ from personal interests, with those of close family or of persons with whom we are involved in a personal business relationship.
It is vital to be independent and to report any commitment or link which may create a potential conflict of interest. We shall avoid situations that may influence our judgment.

FIRA Gifts and Entertainment Policy

We strive to compete on the basis of the quality and value of services provided. You should not offer or accept gifts or payments, or undertake inappropriate activities, to facilitate any engagements. Entertainment of our personnel or clients that is lavish or inappropriate in nature is also not permitted.

In addition, you have an obligation to comply with clients’ policies regarding gifts and entertainment. Gifts or entertainment should not be accepted or extended by you if they could be reasonably considered to:

• Improperly influence FIRA’s business relationship with, or create an obligation to, a client, supplier, contractor, or alliance.

• Violate laws, professional standards and regulations, or this Code of Conduct.

• Constitute an unfair business inducement.

• Cause embarrassment to or negative impact upon our business.

Neither you nor any member of your immediate family should use your position to solicit any cash, gifts, or free services from any client, supplier, contractor, or alliance for your or anyone else’s personal benefit.

Guidelines regarding gifts and entertainment that are acceptable:

• Nominal gifts usual and customary for the profession under € 50,- (e.g., pens, calendars, and mugs).

• Reasonable invitations may be either extended or accepted to business-related meetings, conventions, or conferences under € 200,- (e.g., a product-training seminar, a business lunch or dinner).

• Invitations to social, sporting, or other events may be either extended or accepted if the cost is reasonable and attendance serves a customary business purpose (e.g. networking).

Never accept gifts, meals or entertainment in exchange for doing, or promising to do, anything for a customer or supplier. If in doubt whether a gift is appropriate seek advice from a FIRA Director.

Any donations to charity on behalf of FIRA should be approved by a FIRA Director.

In all cases, you have a responsibility to know and understand FIRA’s detailed guidance on acceptable client entertainment, as well as the client’s own policies related to allowable gifts and entertainment involving their personnel.

Published on January 1st 2013.